Pyle, Nicholas of the Independent Bakers Association, (comment #535221-00027, dated 5/27/2008) offers some interesting suggestions for excluding certain distributorships. I would just suggest the FTC be wary of a minimum payment threshold, since it is not uncommon for fraudsters to require little or no investment going in, but to incentivize ongoing payments to “play the game.” The idea of an exemption based on a supplier’s net worth sounds good, but the assumption that better financed companies are less likely to commit fraud must be challenged. For example, there are billion dollar MLM companies that regularly defraud hundreds of thousands of victims every year. Respectfully submitted, Jon M. Taylor, MBA, Ph.D., Pres. CONSUMER AWARENESS INSTITUTE, and Pres., Jon Taylor & Co., 291 E. 1850 South, Bountiful, UT 84010. Email: jonmtaylor@juno.com